Ashley National Forest Aspen Restoration Project

Status

In October 2019, the Ashley National Forest released the Scoping Letter for the Ashley NF Aspen Restoration Project which will occur on 177,077 acres outside of designated wilderness but can also occur in Inventoried Roadless Areas. Under the Categorical Exclusion, the project is intended to move forward without any input, appeal or objection opportunities from the public, which frees the the Forest Service to cut, burn, masticate, sell, girdle, cut roots, and potentially destroy ecosystem function without any public oversight or input. In December 2019, Y2U along with Alliance for the Wild Rockies and Native Ecosystems Council, submitted comments to the Ashley National Forest regarding the Aspen Restoration Project.

Following is a summary of our concerns:

1. The use of a CE and lack of programmatic or site-specific project NEPA without addressing the circumstances prevailing in this project area. 
2. The lack of site-specific analysis and comparison to ecological criteria, best available science or Forest Plan intent. 
3. The lack of opportunities for public input, objection and appeal. 
4. There was no designation of a cumulative effects area and no analysis of cumulative effects. 
5. Reliance is placed on Best Management Practices (BMPs) instead of science-based criteria under which to manage the project and overlapping uses such as livestock grazing and recreation. 
6. Climate change was not addressed. 
7. There was no analysis of the Regionally Significant Wildlife Corridor, ESA, special status species such as goshawk, Canada lynx or wolverine, or for that matter native plants. 
8. There was no analysis of NFMA viability requirements for special status species. 
9. Old growth was not addressed. 
10. Aspen, livestock, active management, beetles all interactions and outcomes not addressed. 
11. The costs for proposed fencing and other project elements or activities are not defined. Are contractors to be used? Will this occur in the form of timber sales? 

Furthermore, we can find no information that vegetation treatments actually reduce wildfire risk and the evidence we have seen indicates they have many negative effects.

See attachment below for full comments.

Work Plan

• Y2U will continue to monitor the impact of this project on wildlife and habitat.
• Y2U is considering seeking legal representation to challenge the Categorical Exclusion of the NEPA process for this and several other “vegetation treatment” or “fuels treatment” projects.

Expected Outcome

Unknown at this time.